World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and...

In light of McDermott Industries (Aust) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties...

Hungary was the first post-socialist country in eastern Europe to adopt a general anti-avoidance rule (GAAR). The original GAAR adopted in 1990, best described as a "form and substance" GAAR, was supplemented by a second GAAR in 1998, best described as a "proper use of rights" GAAR. The tax...

Australian tax laws have contained a general anti-avoidance rule (GAAR) for over a century. The income tax GAAR proved robust for over half a century but ceased to be effective when read down in the 1970s and was replaced in 1981. The current GAAR has been recently amended to include specific...

The impact of the digital economy on tax compliance, tax bases and tax administration has emerged as a key issue for taxpayers, tax advisors, tax administrators and tax academics. The topic was the focus of the 13th International Conference on Tax Administration organised by the University of...

While the calculation of taxable income under Australian income tax law is similar to the calculation of net profits under accounting standards, there are some fundamental differences between the two systems. These derive in part from the structure of the legislation, in part from the...

Civil law scholars often assume there are general differences in the approaches taken to the interpretation of income tax laws in civil law jurisdictions and common law jurisdictions. However, these differences may be dwarfed by the different approaches taken by two camps within the common law...